E-rate competitive bidding rules require that a Federal Communications Commission (FCC) Form 470 be posted for a minimum of 28 days before filing an associated FCC Form 471 funding request. The E-rate applicant must also follow all E-rate competitive bidding rules. Note that the last date to file an FCC Form 470 and meet the minimum 28-day requirement, and also meet the FCC Form 471 filing deadline of March 25, would be February 26, 2020. It’s important to note, however, that compliance with E-rate competitive bidding requirements, as well as the time necessary to complete an FCC Form 471, make it unrealistic for most applicants to file their FCC Forms 470 on February 26th. Best practices are for applicants to plan for a 30-60 day competitive bidding cycle to allow for unexpected changes, review bids received, and award contracts. If you have not yet posted your FCC Form 470 for Funding Year 2020, and expect that you will need to do so, do not delay. More information on FCC Form 470 and competitive bidding best practices is available on the Universal Service Administrative Co. (USAC) Webinars web page at https://www.usac.org/e-rate/learn/webinars/.

California Funding Commitment Summary

Funding Year 2019

USAC released FY2019 Waves 41 and 42 on January 9, 2020, and January 16, 2020, respectively. Cumulative commitments for California applicants are $289.3 Million.

The deadline for invoicing of Funding Year 2018 non-recurring services is January 28, 2020. This is the last date an applicant may file a FCC Form 472 Billed Entity Applicant Reimbursement (BEAR) form or a service provider may file a FCC Form 474 Service Provider Invoice (SPI) for E-rate reimbursement without an extension.

One-Time Request for Extension

Applicants or service providers needing additional time to invoice MUST submit the request for extension to USAC on or before the January 28, 2020, deadline. Requests received after this deadline cannot be processed by USAC. There is no penalty to file an extension request, and all requests that are filed by the deadline will be granted. If you are in any doubt as to whether or not invoicing is complete on a Funding Request, it is best to file the request for extension.

If an Applicant has a pending post-commitment request that has yet to receive a decision from USAC for any funding requests that would have an invoice deadline of January 28, it MUST file an invoice deadline extension request by January 28, in order to be able to invoice USAC once the post commitment request has been approved by USAC. Typical post-commitment requests include:

For funding requests from Funding Years 2015 and prior, applicants may request the extension in the online BEAR system, by initiating a Customer Service Case initiated in EPC, or by calling the Client Service Bureau (CSB) at 888-203-8100. Service providers must request the extension via the CSB.

FCC Form 471 Filing Window for Funding Year 2020

USAC has announced the annual E-rate application FCC Form 471 filing window for Funding Year 2020. It opened at 9:00 a.m. Pacific Standard Time (PST) on Wednesday, January 15, 2020, and will close at 8:59 p.m. Pacific Daylight Time (PDT) on Wednesday, March 25, 2020. All applicants who are seeking E-rate funding for eligible services delivered between July 1, 2020, and June 30, 2021, must file their annual FCC Form 471 funding requests in USAC’s EPC online portal by the March 25 deadline.

FCC Form 486 Filing Reminder

The FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form) notifies USAC that the billed entity and/or the eligible entities that it represents is receiving, or has received, service in the relevant funding year from the named service provider(s).

Funding Year 2019

FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (“FCDL”) or the start date of E-rate eligible services, whichever is later. For ongoing recurring services, starting on July 1, 2019, the following deadlines have passed or are approaching in the next month.

Waves #

FCDL
Date

Form 486 Due Date

1-25

04/27/2019-09/19/2019

Deadline passed for services starting July 1, 2019

26

09/26/2019

01/24/2020

27

10/03/2019

01/31/2020

28

10/10/2019

02/07/2020

29

10/17/2019

2/14/2020

Funding Year 2018

FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (“FCDL”) or the start date of E-rate eligible services, whichever is later. For ongoing recurring services, starting on July 1, 2018, the following deadlines have passed or are approaching in the next month.

Waves #

FCDL
Date

Form 486 Due Date

1-61

04/20/2018-09/16/2019

Deadline passed for services starting July 1, 2018

62

No California commitments

63

09/30/2019

01/28/2020

64

10/07/2019

02/04/2020

65

10/14/2019

02/11/2020

66

10/21/2019

02/18/2020

Applicants missing these or earlier deadlines should closely monitor their News Feed in the EPC for an FCC Form 486 Urgent Reminder Letter notification. This letter will allow the applicant a 15-day extension to submit an FCC Form 486 without penalty.

Upcoming Training Events

Numerous training opportunities available for E-rate applicants are coming soon.

As the FCC Form 471 deadline approaches on March 25, applicants should allow for adequate time to complete the necessary information for their applications and to submit and certify them by the deadline to be considered “within window.”

Review of Existing Services/Contracts

E-rate applicants should review and verify contracts for all eligible services expected to continue through the next funding year (July 1, 2020, through June 30, 2021), review bills for service and ensure funding requests filed include all eligible services and costs expected, including taxes and surcharges. If you find discrepancies and have already certified your FCC Form 471 funding requests, you may either submit corrections via a Receipt Acknowledgement Letter (RAL) correction, or submit a new FCC Form 471 with the correct information prior to the filing deadline. USAC will require you to cancel any duplicate funding requests.

New Services and Estimating Taxes and Surcharges

E-rate applicants should review any bids and/or new contracts for service to ensure they are complete and include the entire costs of all services you expect to order in the 2020 funding year. If they do not include estimated taxes and surcharges, make sure to include these estimates in your funding requests. Some E-rate eligible services, such as Internal Connections, are subject to California sales tax, while recurring broadband services may be subject to California Public Utilities Commission surcharges. If you are in any doubt as to whether or not your services will be subject to these, contact your awarded service provider for clarification. For current California sales tax rates, please visit: https://www.cdtfa.ca.gov/taxes-and-fees/sales-use-tax-rates.htm. For current California Public Utilities Commission Surcharges, please visit: https://www.cpuc.ca.gov/surchargesfeestaxes/.

Review Certified Applications and File Corrections

Once you have certified your FCC Form 471 application, it is a good idea to review the application for any errors. You may do this by reviewing the live FCC Form 471 in the EPC or by reviewing the PDF version of the original application. From your Billed Entity’s home page in EPC, select the FCC Forms menu to access the Funding Year 2020 certified forms. Each form filed will have a hyperlink taking you to the live form that you may click through to verify information, and also has a PDF link to the original form which you may download.

If you do identify an error, you may submit a request for correction through the Receipt Acknowledgement Letter (RAL) Correction process, see USAC’s Ministerial & Clerical Errors web page at https://www.usac.org/e-rate/applicant-process/competitive-bidding/ministerial-clerical-errors/. Note that only certain FCC Form 470 or FCC Form 471 ministerial and clerical errors may be corrected. If your error does not meet these criteria, it is better to file a new FCC Form 471 with the correct information prior to the filing deadline and to ask USAC to cancel the application that was filed in error. Any errors found after the filing deadline of March 25 must be corrected through the RAL process. Note that RAL corrections may be submitted to USAC up until a Funding Commitment Decision Letter is issued on the FCC Form 471 application.

Respond to USAC Program Integrity Assurance Review

All FCC Form 471 applications undergo Program Integrity Assurance (PIA) review. In some instances, USAC reviewers may reach out to the Contact person listed on the FCC Form 471 to ask questions about the application and/or request documentation to substantiate the eligibility of services, the eligibility of entities receiving services, and the data used to calculate the E-rate discount. Applicants have 15 days to respond to USAC’s request for information and may request an additional seven-day extension. While responses to USAC’s questions occur in EPC, the outreach from USAC will be sent to the Contact’s e-mail address. Failure to respond to USAC’s questions will lead to the denial of the FCC Form 471 funding requests.